Privacy Policy

Privacy Policy

1. Introduction

TruthSpear & Co. (“TruthSpear,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you:

• visit www.truthspear.com;
• contact us or submit an enquiry;
• request information about our services;
• subscribe to communications or insights;
• participate in events, surveys, training, or other activities;
• apply for employment or submit professional information to us; or
• otherwise interact with TruthSpear.

This policy applies to information collected through our website and other business interactions where this Privacy Policy is referenced. Our services include professional services across Audit, Accounting, Consulting, Technology, NGO & Development Advisory, and Risk, Security & Operational Resilience.

1. Information We May Collect

Depending on how you interact with us, we may collect the following categories of information. Personal and Contact Information This may include:

• name;
• job title;
• organization or employer;
• business address;
• email address;
• telephone number;
• country or location; and
• other contact information you choose to provide.

Enquiry and Business Information When you contact us, we may collect information about:

• your organization;
• the services you are interested in;
• business challenges or requirements;
• project details;
• communications with TruthSpear; and
• other information you voluntarily provide.

Please avoid submitting confidential, sensitive, privileged, financial, health, identification, or other highly sensitive information through our general website contact forms unless specifically requested by TruthSpear through an appropriate secure channel. Website and Technical Information When you visit our website, certain information may be collected automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• referring website;
• pages viewed;
• date and time of access;
• approximate geographic location;
• website usage information; and
• cookie or similar technology identifiers.

Recruitment Information If you apply for a position or employment opportunity with TruthSpear, we may collect:

• name and contact details;
• résumé or curriculum vitae;
• educational background;
• employment history;
• qualifications;
• professional memberships;
• references; and
• other information provided as part of an application.

Additional privacy notices may apply to recruitment processes where required.

1. How We Collect Information

We may collect personal information:

• directly from you;
• through our website and contact forms;
• through email, telephone, meetings, or correspondence;
• when you register for an event, training program, webinar, or publication;
• when you apply for a role with TruthSpear;
• through cookies and website analytics;
• from publicly available professional sources; and
• from third parties where permitted by applicable law.

1. How We Use Personal Information

We may use personal information to:

• respond to enquiries and requests;
• provide information about our services;
• assess prospective client needs;
• prepare proposals and engagement discussions;
• establish and manage business relationships;
• deliver professional services;
• administer training, events, or other programs;
• communicate with clients, prospective clients, partners, suppliers, and other stakeholders;
• improve our website, services, and user experience;
• conduct analytics and understand website usage;
• protect our systems, website, employees, clients, and business;
• prevent fraud, security threats, misuse, or unlawful activity;
• comply with legal, regulatory, professional, contractual, or risk-management obligations;
• manage recruitment and employment applications;
• maintain business records;
• send relevant professional insights, updates, or marketing communications where permitted; and
• exercise or defend legal rights.

We will not use personal information for purposes that are materially incompatible with the purpose for which it was collected unless permitted or required by law.

1. Legal Bases for Processing

Where applicable data protection laws require a legal basis for processing personal information, TruthSpear may rely on one or more of the following:

• your consent;
• performance of a contract or steps taken before entering into a contract;
• compliance with legal or regulatory obligations;
• our legitimate business interests, provided those interests do not improperly override your rights;
• protection of legal rights or interests; or
• another lawful basis permitted under applicable law.

The applicable legal basis may vary depending on the circumstances and jurisdiction.

1. Cookies and Similar Technologies

Our website may use cookies and similar technologies to help:

• operate the website;
• remember user preferences;
• understand website traffic;
• analyze how visitors use the website;
• improve website functionality and performance; and
• support security.

Cookies may include: Essential Cookies These are necessary for the website to operate properly. Analytics Cookies These help us understand how visitors interact with our website. Functional Cookies These may remember certain preferences or improve website functionality. Marketing Cookies Where used, these may help measure campaigns or deliver more relevant communications. Where required by applicable law, we will request consent before placing non-essential cookies. You may also control cookies through your browser settings. Disabling certain cookies may affect some website functionality.

1. Analytics and Third-Party Technologies

TruthSpear may use third-party services to support website hosting, analytics, security, communications, email delivery, customer relationship management, forms, and other business functions. These providers may process limited personal information on our behalf. Where appropriate, we require service providers to handle information in accordance with applicable privacy and security requirements. Our website may also contain links to external websites. TruthSpear is not responsible for the privacy practices, security, or content of websites operated by third parties. We encourage users to review the privacy notices of third-party websites before providing personal information.

1. Marketing Communications

Where permitted by law, we may send professional updates, invitations, insights, newsletters, service information, or other business communications. You may unsubscribe from marketing communications at any time by:

• using the unsubscribe link in an email, where available; or
• contacting us using the details provided below.

We may continue to send communications that are necessary for an existing client relationship, transaction, legal obligation, or administrative purpose.

1. Sharing of Personal Information

TruthSpear does not sell personal information. We may disclose personal information where reasonably necessary to:

• TruthSpear personnel and authorized representatives;
• affiliated or associated entities, where applicable;
• professional advisers;
• technology and hosting providers;
• email and communications providers;
• analytics providers;
• contractors and service providers;
• business partners involved in delivering a requested service;
• regulators, courts, government authorities, law-enforcement agencies, or professional bodies where required; or
• another party in connection with a restructuring, merger, acquisition, sale, financing, or transfer of all or part of our business.

We seek to limit disclosures to information reasonably necessary for the relevant purpose.

1. International Transfers

TruthSpear may operate, provide services, or engage service providers across multiple jurisdictions. As a result, personal information may be transferred to, processed in, or stored in a country different from the country in which it was originally collected. Where required by applicable law, we take appropriate steps designed to ensure that international transfers are subject to suitable safeguards. Privacy and data protection laws vary between jurisdictions.

1. Information Security

TruthSpear uses reasonable administrative, organizational, technical, and physical safeguards designed to protect personal information against:

• unauthorized access;
• misuse;
• alteration;
• loss;
• destruction; and
• unauthorized disclosure.

However, no internet transmission, electronic storage system, or security measure can guarantee absolute security. Users should therefore exercise appropriate care when submitting information electronically.

1. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable:

• legal obligations;
• professional requirements;
• contractual obligations;
• regulatory requirements;
• accounting requirements;
• security requirements; and
• legitimate business needs.

Retention periods may vary depending on the type of information and the nature of our relationship with you. When personal information is no longer required, we may securely delete, destroy, de-identify, or anonymize it, subject to applicable requirements.

1. Your Privacy Rights

Depending on where you are located and the law applicable to your personal information, you may have certain rights, which may include the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of personal information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• request portability of certain information;
• opt out of certain marketing communications; and
• lodge a complaint with an appropriate data protection or regulatory authority.

These rights are not absolute and may be subject to legal exceptions. To exercise a privacy right, please contact us using the details below. We may need to verify your identity before processing certain requests.

1. Children’s Privacy

TruthSpear's website and professional services are generally intended for organizations, professionals, business users, and adults. We do not knowingly seek to collect personal information from children through our general website. If we become aware that personal information relating to a child has been collected in circumstances where consent or other authorization was required, we will take appropriate steps in accordance with applicable law.

1. Professional and Client Information

Where TruthSpear provides professional services to a client, additional confidentiality obligations, engagement terms, professional requirements, contracts, or privacy notices may apply. This website Privacy Policy does not replace contractual confidentiality obligations contained in a client engagement agreement. Information provided to TruthSpear does not by itself create a client, adviser, fiduciary, professional, or other engagement relationship. A professional relationship is established only when expressly agreed by TruthSpear through appropriate engagement documentation.

1. Third-Party Links

Our website may contain links to third-party websites, platforms, publications, or services. These third parties operate independently of TruthSpear and may have their own privacy policies. TruthSpear is not responsible for the privacy, security, content, or practices of third-party services.

1. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• changes in our business;
• changes to our website or services;
• developments in technology;
• regulatory requirements; or
• changes in applicable law.

The updated version will be posted on this page with a revised “Last Updated” date. We encourage users to review this Privacy Policy periodically.

1. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or the way TruthSpear handles personal information, please contact: TruthSpear & Co. Website: www.truthspear.com Email: info@truthspear.com Privacy Enquiries: privacy@truthspear.com (recommended — create this mailbox if you do not already have one) You may also contact us through the website's Contact Us page.

1. Jurisdiction-Specific Rights

Privacy rights vary by jurisdiction. Where applicable, TruthSpear will process personal information in accordance with relevant privacy and data protection laws governing the particular processing activity. Individuals located in jurisdictions that provide additional statutory privacy rights may exercise those rights subject to the requirements, limitations, and exemptions provided by applicable law.